193 



Finally, the sludge that is currently disposed of at the 12-mile 

 site would have to be disposed of in some other location or medium, 

 each of which presents its own potential for environmental or 

 human health effects. 



The one other point I would like to comment on very briefly con- 

 cerns some of the additional results that we have generated as part 

 of our special permit application preparation which will be final- 

 ized and presented to EPA by the city this summer. 



We have done extensive laboratory programs, completed exten- 

 sive chemical analyses on toxicity and bioaccumulation of sludge. 

 This work has shown that toxicity is relatively low. We are finaliz- 

 ing a sewage sludge dispersion model and based on preliminary re- 

 sults it appears that most of the city's 12 sewage sludges will meet 

 the limiting permissible concentration requirement at the 12-mile 

 site. 



Tests have shown no evidence of significant bioaccumulations in 

 organisms due to exposure to sewage sludge in seawater. 



Thus, it appears that the sewage sludge from most if not all of 

 New York City's waste treatment plants will satisfy the environ- 

 mental criteria of the regulations for ocean disposal. 



I think based on both our site designation documents and the 

 work that we will include in the special permit application which 

 will also include a multimedia risk assessment, looking at the risk 

 to man for ocean disposal and land-based alternatives — that a 

 strong case will be made for continued ocean disposal at the 12- 

 mile site. 



Thank you. 



[The statement of Mr. Gift follows:] 



